G.R. No. L-23958 September 28, 1968
EASTERN PAPER MILLS EMPLOYEES ASSOCIATION-NATU, petitioner, vs. EASTERN PAPER MILLS, INC. and HON. GUILLERMO E. TORRES, respondents.

FACTS

The petitioner, Eastern Paper Mills Employees Association-NATU, a labor union of the respondent company’s employees, declared a strike on October 9, 1964, alleging the company’s unfair labor practice of bad faith in collective bargaining. On October 12, 1964, while settlement talks were ongoing, the respondent company filed a civil case for damages (Civil Case No. 8416) with the Court of First Instance of Rizal. The following day, the respondent judge issued an ex-parte restraining order against the striking employees’ picketing activities. The petitioner moved to dismiss the case and dissolve the order, arguing that the labor dispute and unfair labor practice charge fell under the exclusive jurisdiction of the Court of Industrial Relations (CIR). The motion was denied on December 2, 1964. The petitioner then filed this certiorari and prohibition case, challenging the CFI’s jurisdiction and the issuance of the restraining order. The respondent company contended the CFI had jurisdiction over its claim for damages arising from alleged tortious conduct during the strike. It was also revealed that on October 30, 1964, the company filed an unfair labor practice complaint (No. 4266 ULP) with the CIR.

ISSUE

Whether the Court of First Instance of Rizal or the Court of Industrial Relations has jurisdiction over the complaint for damages allegedly arising from unlawful acts committed during a labor dispute.

RULING

The Supreme Court ruled partially in favor of the petitioner. It declared the ex-parte restraining order issued by the CFI illegal and void for violating the specific procedure under Section 9(d) of Republic Act No. 875 (The Industrial Peace Act), which governs injunctions in labor disputes. However, the Court upheld the CFI’s jurisdiction over the complaint for damages at that stage. The criterion for determining jurisdiction is whether the acts complained of are connected with an unfair labor practice case. The Court found that while an unfair labor practice case was later filed with the CIR, the petitioner, in its motion to dismiss before the CFI, merely alleged the existence of such a case without submitting competent evidence (like a copy of the complaint) to clearly show the connection between the two cases. Since the CFI asserted jurisdiction in the absence of a sufficient showing of interrelation, and the petitioner did not file a motion for reconsideration to further support its allegation, the CFI’s order denying the motion to dismiss was not issued without jurisdiction or with grave abuse of discretion. Nevertheless, the Court directed the CFI to suspend proceedings on the damages claim until the related unfair labor practice case before the CIR is terminated, as the right to damages would depend on the evidence in that case. The writ of certiorari was granted only with respect to annulling the restraining order.